The services offered and the way they are advertised to the public should be the determining factor in how a firm and its representatives are governed. How they are paid for is a secondary issue. If financial planning, wealth management, financial advising, comprehensive planning or anything in the nature of advice or planning is the service, then that person or firm should be registered as an Investment Advisor or Investment Advisor Representative and be subject to the advisor rules. Any other distinction is misleading to consumers. Please drop the Merrill Lynch Rule.